Struggles in The Accounting Arena: A Geopolitical Reading of Romanian Accounting Reforms

Research Article
Accounting History
2023, Vol. 28(1) 143–169
Struggles in the accounting © The Author(s) 2022
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DOI: 10.1177/10323732221109658
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Raluca Sandu
SKEMA Business School – Université Côte d’Azur
Dragos Zelinschi
Nantes Université, IAE Nantes, LEMNA
Laurence Ferry
Durham University
Abstract
Transition economies have undertaken an accelerated series of reforms after the collapse of communism, aim-
ing at the (re)construction of market institutions. In this paper we build on a geopolitical perspective, and on
accounting profession literature to map the accounting reforms in post-communist Romania. We find that
accounting reforms are reflecting broader processes of globalisation and Europeanization. By examining the
‘territorial’ disputes over the Romanian accounting reform and the successive leadership of groups of experts
from France and United Kingdom we draw attention on the drivers of accounting reforms. These are not lim-
ited to the technical aspects of accounting and the interests of the actors, but have their roots embedded in the
broader geopolitical setting. In the case of Romania, the European Union accession guides the path and pace of
accounting reforms, having as general background the globalisation of accounting regulation.
Keywords
accounting reform, transitional economies, globalization, accounting harmonization, accounting profession
Introduction
A big issue concerns how countries transition between different types of economies, and the role of
accounting in this process. After the collapse of communism in Eastern Europe in the late 1980’s
and early 1990′ s, transition represented the passage from a planned economy to a free market
economy. Transition was therefore a dynamic historical process, implying change at all levels
Corresponding author:
Raluca Sandu, SKEMA Business School - Paris, 5 Quai Marcel Dassault, 92150 Suresnes, France.
Email: r.sandu@skema.edu
144 Accounting History 28(1)
(Havrylyshyn and Wolf, 1999). Ex-communist countries represent an experimental field for some
theorists of the market economy, acting as ‘doctors’ for these young, reconfigured economies
(Akimov and Dollery, 2008; Sandu, 2017). Moreover, these markets give space for experiments;
they are no longer seen as abstract economic coordination mechanisms, but as a space to be actively
organised (Mennicken, 2010; Sandu, 2017). In the process of transition, international financial
organisations, development aid agencies, and experts from developed countries play a strategic
role, helping to shape local practices and institutions. In this setting, accounting (as a set of national
rules, techniques and practices) has to be fundamentally reformed, to change from a role of inform-
ing the plan in the communist regime, to a role of informing investors in the context of the new
emerging market. This process takes place in a particular geopolitical context that enables us fol-
lowing Hopper et al. (2017) to question the role of accounting in development policies.
It is therefore important to understand the links between the local and global context and the
drivers of accounting reforms in the context of two juxtaposing processes, which are transition
to the (European) market and globalisation. Transfer of practices from developed countries to tran-
sitional or emerging economies can provide a rich framework for understanding how local practices
and institutions are shaped (Mennicken, 2010; Caramanis et al., 2015), as well as related research
on the role of professional accounting firms as vehicles of professionalisation and accounting regu-
lation (Caramanis, 2002; Cooper and Robson, 2006).
However, there is still limited research in this area, so the purpose of our paper is to explore the
accounting reform as a space of struggles and competition, where accounting is being actively reor-
ganised by a plurality of actors and forces at the national and global level. These sometimes com-
peting, other times converging forces, reflect the strategies of foreign countries (including support
for development) to sustain broader processes of globalisation and Europeanisation (for those in the
European Union (EU) sphere).
Similar to other research, we aim with our study to map accounting reforms across the institu-
tional and political transformation of a country (Yapa et al., 2016). The context of our study con-
cerns Romanian accounting reforms between 1989 and 2007, undertaken as part of the transition
from communism to free market and EU accession. With our paper, we provide a detailed analysis
of the successive accounting reforms in Romania, depicted in the local literature as ‘a jungle of the
accounting reform’, or ‘reform after reform’ (Feleagǎ , 1996; Malciu and Feleagǎ , 2005). We focus
on the transition from communist planned accounting to an accounting system adapted to the
market in the perspective of EU integration, which finally occurred in 2007. This transition con-
sisted of an initial phase inspired by French accounting, followed by an abrupt turn to an accounting
system based on International Financial Reporting Standards (IFRS), supported with expertise from
the Institute of Chartered Accountants of Scotland (ICAS).We explain the sudden turn from French
inspired reform to an Anglo-Saxon driven reform as a matter of geopolitics, where accounting
becomes an instrument of Europeanisation.
Even if no direct confrontation opposed the foreign intervention of experts in the Romanian
accounting reforms, it was however an asynchronous confrontation of accounting regimes, taking
as the ‘battlefield’ the uncharted accounting territory of post-communist countries. It reflects in
this way the struggles that are taking place on a more global arena, where national and global
logics are confronting each other in shaping international regulation (Djelic and Sahlin-Andersson,
2006). This episode at the periphery reveals the twists and turns of accounting reforms in transition,
supporting the idea that accounting regulation is not a neutral framework, but it translates a broader
geopolitical setting. Moreover, even if the Romanian context cannot be directly qualified as a post-
colonial one, it is interesting to note that the various influences exerted by France and the United
Kingdom (UK) use post-colonial ‘recipes’, which reflect a know-how and strategies developed in
a post-colonial setting. This means our case can shed some light on how the local accounting
Sandu et al. 145
reforms in a post-communist country are shaped by the direct or indirect intervention of Western
countries, following processes of Europeanisation and globalisation. Also, our paper sustains the
claim that globalisation is not a uniform linear process, and that tensions, confrontations and alliances
are part of this movement.
We also find that the twists and turns of accounting reforms in Romania are impacted by geo-
politics, like the transformational diplomacy lead by the UK after the cold war, as well as the
European Union (EU) accession process. Moreover, we find that accounting academics play an
active role in bridging between the planned economy and market, due to the absence of trained
accountants and of an organised accounting profession. Therefore, we bring a contribution to the
accounting profession literature.
Next in section two of the article we introduce a quick historical overview, including the main
steps in EU accession, and the origins of French influence in Romania. This is followed by section
three that covers the main literature for our theorisation, namely geopolitics of accounting, and
accounting profession. In section four we provide a description of our methodology introducing
the research context and methods. This section explains the accounting harmonisation process at
the EU level, and the successive stages of the accounting reform in Romania in the context of
EU accession. Next, in section five, the findings are set out, following the pace and path of account-
ing reforms under the French and UK influence. In section six, the discussion is developed around a
geopolitical reading of accounting reforms, and the role of academics in the reforming process.
Finally, in section seven, the conclusion section discusses the contributions of the article, and
opens new avenues for research.
General background: a historical overview of Romania, and the roots of

French influence
The research context sets out the transition from Communism to EU accession and accounting har-
monisation for Romania, a country with a mosaic of influences and geographical settings placing it at
the cross-roads of powers and interests. In particular, it will consider the French roots of influence.
Historical overview
A quick overview of Romanian history reveals it is strongly influenced by the country’s geography,
namely by its place on the world map, its topography and hydrography (Sandu, 2008). Thus, the
history of Romania, full of unsolved contradictions, is played out in a space of borders
(Durandin, 1995) between East and West (Hitchins, 2014).
From an intellectual point of view, the Romanian nation emerged in the eighteenth century
(Hitchins, 2014), but the space claimed by the Romanians was for a long time fragmented into
the separate principalities of Moldova, Valachia and Transylvania. Later reunited: the moldo-
valaque unit dates from 1859, the formation of the Great Romania from 1918 (Durandin, 1995).
‘Between the 1860s and the decades between the World Wars, which constitute the national
period, modern Romania took form politically, economically, socially, and culturally, in accord-
ance with the European model’ (Hitchins, 2014: 2). After WWI, the country expanded considerably
(the size and population more than doubled) thus developing into a regional power. The relative
prosperity of the interwar period was followed after WWII by the installation of a communist
regime in 1947, Romania becoming part of the Eastern bloc. The fall of the Communist regime
in 1989 opened a turbulent transition period towards democracy and a market economy, but even-
tually Romania joined the North Atlantic Treaty Organization (NATO) in 2004 and the EU in 2007.
The period under study in this paper covers the years 1989–2007, between the fall of communism
and the EU accession. Transition to the European market is a complex process, with several layers
of overlapping reforms, in a turbulent international context. The timeline in Figure 1 shows some of
the most relevant events for EU accession that punctuated this period, and that provided a back-
ground to accounting reforms in Romania.
Figure 1. Significant events between 1989–2007 (EU and NATO accession).

Source: Official information from the institutional websites of the EU (www.europa.eu) and Romanian
Government (www.gov.ro)
Sandu et al. 147
French influence
It is particularly relevant to this paper to observe the strong French influence in the history of
Romania, setting grounds for cultural affinities and early choices in the transition from communism
to the EU market. However, it should be pointed out that this influence is partly mythical (Boia,
2001; Sandu, 2008) and its weight and manner of expression varies considerably over time. On
a political level, France has always been a traditional ally of Romania (Durandin, 1995) and
played a central role during the major events that marked the country’s history: organisation of
the Paris conference which led in 1859 to the union between Wallachia and Moldova (Castellan,
1994), support during the 2nd Balkan war (Hitchins, 2014) and support (including military assist-
ance, through the Berthelot mission) during WWI (Castellan, 1994; Hitchins, 2014).
The origins are relatively recent and are set in the mid-nineteenth century, when the young enligh-
tened Romanian elites travelled to Paris and came into contact with European romanticism (Castellan,
1994; Boia, 2001). The cultural and political ideas that crystallised at that time would have a profound
impact on the political and intellectual life of the country for at least one century (Durandin, 1995).
Even the Romanian language has significantly evolved under French influence, to the point that today
approximately 20 percent of the current vocabulary is of French origin (Boia, 2001).
During the interwar period, Romanian cultural circles remained receptive to French academic
ideas, but in the 1930s competition emerged between French, German and Italian perspectives;
moreover, during the same period, Romanian nationalist movements clearly displayed an
anti-French attitude (Durandin, 1995). Before the outbreak of WWII, ‘the relationship with
France was not merely political; it grew out of the Romanians’ perception of a general community
of interests between the two countries of mutual comprehension and even affection’ (Hitchins,
2014: 197). However, some dissensions arose, as France criticised the political instability and
the rise of the extreme right in Romania. Nevertheless, it still explicitly supported Romania’s
desires for external policy - to preserve and have recognised the achievements of 1918–1920
and to maintain regional stability (Durandin, 1995).
After 1945 and the establishment of the communist regime, Romania shifted towards the East,
especially towards the Union of Soviet Socialist Republics (USSR). In the 1960s-1970s there was a
change of course with the development of closer ties with Western countries, a movement that
France accompanied and encouraged. Later the regime hardened again, and French intellectuals
supported the Romanian dissident movements (Durandin, 1995). In the 1980s, the West became
concerned about the rule of law and certain social issues, and in 1989 the French Prime Minister
made a speech at the United Nations (UN) condemning Romanian policy (Durandin, 1995).
Following the fall of Communism in Romania in 1989, since 1993 Romania has been a member
of the International Organisation of French-speaking countries (Organisation Internationale de
la Francophonie), even though French is not its official language.
Literature review
Our paper builds on two streams of research, providing first a geopolitical reading of accounting
reforms in transition to market, and second, focusing on the role of accountants and accounting pro-
fession in this process.
Colonies without empire: the geopolitics of globalisation

The role of international financial organisations in the transition of countries has been already
underlined in the literature, and the research on globalisation acknowledges their central position,
based on the nature and the relations they establish with the local actors. Most of these studies
analyse the role played by World Bank and International Monetary Fund (Neu et al., 2002;
Saravanamuthu, 2004; Annisette, 2004; Murphy, 2008). International organisations have certainly
a role to play in shaping the ‘new global managerial order’ (Murphy, 2008), and the perspective
taken in previous research is based on imperialism, and global governance frameworks
(Annisette, 2000). Murphy (2008) considers that ‘while the international financial institutions
have achieved a certain notoriety in western countries, their strategic involvements in developing
transitional countries have received relatively little critical scholarly attention’ (2008: 73).
Also, there is a rich literature on accounting in post-colonial contexts (Chua and Poullaos, 2002;
Poullaos and Uche, 2012) where accountancy is seen as a vehicle for the dissemination of devel-
oped countries’ institutions and practices, which includes the UK (Poullaos and Sian, 2010).
This can be seen as part of the globalisation process. Hopper et al. (2017) addresses the question
of influence and transmission of know-how in the context of globalisation and look at particular
strategies deployed by developed countries as vectors of post-colonial intervention in the context
of developing countries.
Moreover, a vast body of literature looks at forms of resistance or independence from the colo-
nial power (Davie and McLean, 2017). Hopper et al. (2017) plead for a balanced point of view. This
involves on the one hand the introduction of Western accounting practices that can be seen as a
post-colonial process aimed at disseminating capitalist ideology, but on the other hand it allows
for a better integration of developing countries in the global economy even enabling them to
exert a positive influence. The actual impact of accounting reforms should be therefore nuanced:
A recurring research finding is that whilst basically sound accounting and accountability systems were often
adopted and maintained, in actuality they played a ceremonial role to gain legitimacy from the populace and
external funders, and played little part in ministerial and parliamentary scrutiny or decisions (Hopper et al.,
2017: 128).
Yapa et al. (2016) claim that this colonial and post-colonial literature privileges the British story
and there are few examples of the institutional accounting and professional legacy of the other colo-
nial powers. Moreover, the call for more studies in other settings is not new, and yet still
unanswered (Cooper and Robson, 2006). We aim to fill this gap and add a new setting to this
increasing body of literature, focusing more specifically on transition and the Europeanisation
context.
It needs to be noted that Romania is not a former colony by the definition of the term, but we
contend that this setting can shed some light on the way in which developed countries are deploying
strategies for influence, or support for new democracies, as part of a post-colonial global setting. In
this perspective, we consider that ‘…imperialism can exist without (formal) empire and (…) might
continue in various forms. The rise of the US could be described as a new variety of informal
empire’ (Poullaos and Sian, 2010:1).
Moreover, the collapse of communism opened overnight a new market on the global arena, cor-
responding most often to an unchartered accounting arena, as the accounting adapted to the need for
reforms to the planned economy. The case of China sheds light on reforming processes, where
Western ideas (embodied in the International Accounting Standards (IAS) were coupled with a
strong concern for preserving local identity (Ezzamel and Xiao, 2015).
Moreover, Djelic and Sahlin (2006: 267) point out, building on Bourdieu that ‘the opening up of
new social spaces – and international standard-setting arenas are such spaces – is likely to generate
conflicts over the material and symbolic occupation of this space’. Our study adds to this literature
by focusing on transitional economies and accounting reform arenas as such spaces generating
Sandu et al. 149
struggles and competition. Moreover, it is acknowledged that accounting plays an important role in
globalisation processes, as accounting developments, and more specifically standardisation, are part
of a broader global movement (Ahrne and Brunsson, 2006; Drori and Meyer, 2006). The fall of
communism in 1989 reshuffled the geopolitical tectonic plates, and we therefore contribute to
the literature on the role of accounting in globalisation, by focusing more specifically on the tran-
sition to (EU) market approaches in post-communist countries.
Accounting profession, gaps and continuity

Accountants and the accounting profession play a particular role in the accounting reforms in post-
communist countries that include Romania, both by the absence of an organised profession in the
early stage, and by the role played by academics in bridging knowledge, practices and know-how
over transition.
There is a rich literature on the role of the accounting profession in the context of economic
development, transition and transmission of practices from western countries to young economies.
For example, in Greece, Caramanis (1999, 2002) identifies a local competition between profes-
sional elites willing to modernise, against those seeking to conserve accounting practices.
Other studies identify more subtle influences than the direct forms of colonialism, like for
instance education, cultural background and affinities (Annisette, 1999; Cooper and Robson,
2006), with the purpose of expanding power and leadership of accountants from developed coun-
tries. The role of ethnicity as well as of rivalry between local groups, or a foreign and a local pro-
fession is already explored in the literature (Caramanis, 1999, 2002; Annisette, 2003; Cooper and
Robson, 2006). However, in the case of transitional Romania we have an example of central
powers’ rivalry, and competition for reforming accounting in a transitional country, at the periph-
ery, similar to that observed by Yapa et al. (2016) in the case of Cambodia. Indeed, in the early stage
of the accounting reform in Romania, no professional accounting elites had been formed. The role
of the accountant as practitioner, and as professional, was minimised in the communist society, with
the dismantlement of the accounting profession, accordingly another indirect struggle took place,
between the French and UK accounting expert teams, for reforming accounting in Romania.
By examining the role of expert teams from developed countries in driving accounting reforms
for the transition of a country’s planned economy to a market economy, as well as by identifying the
struggles to step in uncharted accounting territory, we intend to fill a research gap as ‘much more
can be done about the potentially variable roles that accounting plays in special versions of capit-
alism’ (Cooper and Robson, 2006: 420).
Accountants are not representing (only) their own interests, with national agencies from devel-
oped countries part of a complex web of relations and alliances within the global governance,
although literature has often overlooked the complexity of relations between national and inter-
national agencies (Caramanis, 1999, 2002; Cooper and Robson, 2006). Moreover, limited work
has considered the way in which accounting reforms are driven and shaped by the competing inter-
vention of experts from developed countries, and how they act locally for gaining leadership in
reforms. Our study fills this gap, by focusing on the competition between the French and UK
(Scottish) teams of experts for gaining leadership in the Romanian accounting reform, and how
this is part of a broader geopolitical setting. In addressing this question, we add relevant insights
to the accounting profession literature. Yapa et al. (2016) show in their paper that the rise of the
accounting profession is seen in the literature as an answer to the development of industrial
society, with some authors considering it a mean to preserve and reproduce privilege, while
others depicted it as an ‘expression of external forces associated with colonialism, domination
and globalisation’ (Yapa et al., 2016: 401). We consider that in our case, processes of
Europeanisation and globalisation are relevant to explain the path of accounting reforms in a post-
communism context, therefore answering to a call to address differently the professions’ struggles,
which are not limited to conflicting or aligned interests, but reflect and resonate with broader social
and political processes. In this sense, accounting is represented as a ‘space of competition and strug-
gle’ (Yapa et al., 2016) embedded in the global political arena.
Moreover, the literature does not often address the absence of profession(s) in a country. One
notable exception is Yapa et al. (2016), identifying the absence of an organised profession as a rele-
vant explanatory factor for the evolution of accounting in Cambodia. In the case of former colonies,
existing literature would suggest three different alternatives: the creation and rise of a state-
supported local body; the re-establishment of professional institutions associated with the historical
colonial power (France); or the growth of professional bodies directly linked to globalised profes-
sional associations (Yapa et al., 2016). The authors link the accounting practices and evolution of
accounting bodies with the birth and development of industrialisation. The specific context of China
(Zhu et al., 2021) raises different questions related to state-accounting relations, identifying a heter-
onomous influence of the state on the accounting field, as well as a major role of the state in pro-
ducing doxa in accounting. The accounting profession proves to be here an extension of the state,
which departs from similar studies on Western contexts, where professional bodies are built on
liberal principles.
Bailey (1975) previously explained the difference in social status between accountants of
Eastern Europe and those of the West by the completely opposite ways in which economic activities
are integrated at the micro-economic level in the two types of society. The free market implies the
existence of specific institutions (financial markets, entrepreneurship), while the planned economy
entails the existence of planning agencies and planners. Within this system, accounting is an appro-
priate mechanism of monitoring the flow of resources, and output of goods, and of exercising finan-
cial control over the company (Bailey, 1975). Great differences of professional and social status are
observed between the accountant of the Western countries and the accountant of Soviet Union
based on an analysis regarding the USSR. Accountants’ lower status in USSR compared to
Western countries can be explained by the regression of accounting to book-keeping, and the
fact that accounting was mainly reduced to recording procedures during the centrally planned
economy (Bailey, 1975). This also applies to the Romanian society of the same period, considering
particularly the absence of an organised profession.
In Romania, an organised accounting profession existed before the communist era and was dis-
solved during communism. Based on the article by Zelinschi (2009), more studies on the emergence
and evolution of the accounting profession in Romania have followed (Farcas et al., 2012; Mutiu
and Tiron, 2010; Zelinschi, 2012). The facts analysed in these studies are related to the creation in
the early twentieth century of the Professional Body of Certified Accountants, which was to be dis-
solved at the beginning of the communist regime, this profession remaining disorganised until
1992, when a new professional body was to be created. The literature does not address the question
of the absence of the profession in the early stage of the reforms, and we address this gap by looking
at the interim leading role of academics during the first stage of the accounting reforms.
Calu (2005: 203) already observed that during the communist period, in Romania, despite the
closure of the system, there have been some studies carried out by researchers (academics) to
study the possibility of changing accounting standards, according to a Western model, but which
remained peripheral and often unpublished, given the political context. The author cites an unpub-
lished material, dating from 1984, which referred to the French accounting doctrine and proposed
the modernisation of the accounting system. In the same vein, the study of Bockman and Eyal
(2002) shows that relations between Eastern and Western scientists existed even at the time of
the Cold War, and the networks that were thus created (especially among economists) provided
Sandu et al. 151
a material basis for the spreading of neoliberal ideas after the revolution. In this way, despite the
absence of market practices, a part of the elite was prepared for reform and, after the fall of com-
munism, has acted and gained new positions and power.
Therefore with our paper we contribute to two streams of research: (1) accounting profession, by
bringing light on the role of experts and accounting academics in reforming accounting for the
market, and (2) accounting regulation and globalisation, by showing that accounting reforms in
transitional countries are not following a linear process towards an efficient system technically
adapted to the market, but they are reflecting (and constitute an arena for) broader struggles in
the process of globalisation.
Methodology
Research context: European accounting harmonisation and accounting reforms in
Romania
Accounting harmonisation represented one of the means of the economic integration envisaged by
the Treaty of Rome of 1957. Three European accounting directives were successively published:
the fourth (1978) defining the objectives, the presentation and the contents of the financial state-
ments, the seventh (1978) regarding group accounts and the eighth (1984), about legal audit.
These three directives represented until 2005 the basis of accounting harmonisation within the
EU and they undoubtedly led to a relative alignment of accounting practices.
However, because of the way these EU directives had been conceived, they did not bring a suf-
ficient degree of harmonisation and standardisation, in a context where more and more countries
and companies (including the former Eastern Bloc, undertaking a massive privatisation process)
tried to raise funds abroad, and foreign investors arrived on the national markets. A large
number of possible options were allowed and during the transposition of the directives the national
legislators could choose the option to implement, therefore each country succeeded in maintaining
its accounting tradition. In addition, many controversial topics had been ignored and the only ref-
erence point was the true and fair view, which left much freedom for the various national States.
The European harmonisation process was rather slow and constantly lagging the evolutions in
the financial and economic fields; consequently, the directives had quickly become obsolete.
Moreover, certain divergences existed between them, as they had been elaborated in different eco-
nomic and political context.
At a global level there was an actual market for accounting standards, where the European direc-
tives competed with the increasingly influential IAS (today IFRS), but also with the US GAAP.
Business companies could choose between various accounting frameworks, depending on the
intended purpose (Barbu, 2004).
At the end of the 1980s the harmonisation process at the European level virtually stopped,
while national standard setters continued their work in an uncoordinated way. In 1990, the
Commission organised a conference on the future of accounting harmonisation within the EU
where the majority of the participants spoke out against the reduction of the number of
allowed options (at a time when the International Accounting Standards Committee (IASC))
decided to allow only two options). Following this conference, the Commission set up an
accounting advisory forum, but this body did not have any notable influence. At that time, the
harmonisation of the European system started to crumble: the comparability of the accounts wor-
sened because of the separate evolution of the national accounting standards and companies pre-
ferring either the US GAAP or the IAS, which were frameworks regarded as internationally
recognised (Colasse, 2009).
At the end of 1994, the decision of an alliance with the IASC was taken, as it was the only insti-
tution offering a framework accepted by the international markets (apart from the USA standard
setter1). Eventually, in 2000 the European Commission adopted a new harmonisation strategy
for the EU, namely the application of the international IASC standards by all listed European
groups. Setting up a unified capital market called for a true accounting standardisation, as the pre-
vious accounting harmonisation, allowing certain variations, was no longer sufficient. A new regu-
lation published in 2002 required that publicly traded companies prepared their group accounts in
accordance with the IASC standards starting in 2005.
Romania started the EU accession process in 1999 and became a member in 2007. Table 1 pre-
sents the overlapping reforms after the fall of communism, and the rebirth of the accounting pro-
fession in the same period. This visualisation explicitly illustrates the pace and focus of reforms
in the preparation of the EU accession and links the major stages to the steps taken in the official
accession process. It is very important thus to closely scrutinise the background of accounting
change in Europe, and more specifically the process of international accounting harmonisation.
It is in this context of EU accession and accounting harmonisation that we will map the account-
ing reforms in Romania, with direct assistance from French and UK missions, plus the specific role
of accounting academia in the professionalisation of transitional economies.
Research methods
The paper draws on interviews and secondary documentation. The thirteen interviews provided
insights on debates over the Romanian accounting reform, which are summarised in Table 2.
Eight of the interviews (IC), conducted with actors from a variety of backgrounds, provide a
general understanding of the context of transitional Romania and they are relevant for understand-
ing the general economic and financial environment after the fall of communism.
The other five interviews (IA) are directly related to the accounting reform. Two interviews were
conducted with actors (one French, one Romanian) involved in the accounting reform, during the
period under study. Two other interviews were conducted with UK participants to various inter-
national advisory missions in Eastern European countries. One interview was conducted with a par-
ticipant to the mission in Romania, a French expert accountant and member of the management of
the French professional association at the time.
Most of the interviews (with the exception of the last three) were conducted in the period May
2010 - May 2011 in Romania, and in the case of one interview in France. They took between 50
minutes and 1 hour and 40 minutes, with an average of 1 hour and 20 minutes. The three additional
interviews were conducted in 2018–2019. Nine interviews were taken in Romanian, two in English,
and two in French. Two of the authors, directly involved in the data collection, speak fluently all
three languages used in the interviews.
Secondary sources include publications of government agencies, academic and practitioners’
reports, as well as on an extensive body of accounting regulation in Romania and Europe. Table 3
provides a list of Romanian accounting regulations from the period under study, used in our analysis.
Regarding data analysis, two of the authors established themes from the data individually, and
then together, as an iterative process. In the findings section, we have chosen to present successively
the two phases of the reform (under French influence, and under UK influence), as a way to struc-
ture the episodes of our story. Then, the main themes emerging from the analysis of the interviews
and secondary data were grouped around two themes that structure and drive the discussion of our
findings in section 6, namely the role of academics in the accounting reform, and the geopolitics of
accounting. The text selected to be included in the article that were originally in a language other
than English were translated by the author who undertook the interview.
Table 1. A synoptic table of relevant events at the Romanian and European level after the fall of communism, and before eu accession.
1989 1990 1991 1992 1993 1994 1995 1996 1997
Significant Fall of the Berlin wall; Reunification of Dissolution of Soviet The Treaty on the EU is Maastricht Treaty Hungary and Poland Austria, Finland and The Czech Republic and Euro-Atlantic Partnership
Sandu et al.
events Fall of communism Germany; A special Union; Beginning of signed in Maastricht creating the EU and formally apply to Sweden become Slovenia formally Council (EAPC), a post-
in all the countries European Council Yugoslav wars; by the foreign and the single European join the EU; An members of the apply to join the Cold War
of the Warsaw pact is held in Dublin, "Europe finance ministers of currency; inaugural EU; European EU; The EU signs NATO institution is
(including Ireland. It agrees on Agreements" are the Member States; Negotiations on conference for a Association partnership and co- created.
Romania), except a common signed with Poland, The Council adopts the accession of Stability Pact for Agreements are operation
for the Soviet approach to Hungary and a regulation on the Austria, Finland and Central and signed with Estonia, agreements with
Union. German unification Czechoslovakia. extension of the Sweden begin in Eastern Europe is Latvia and Georgia, Armenia
and European economic aid Brussels. Europe held in Paris, Lithuania; and Azerbaijan.
Community programme Agreement on France. Romania, Estonia,
relations with (PHARE) to trade-related Lithuania and
Central and Slovenia. matters signed Slovakia apply to
Eastern European with Romania. join the EU.
countries;
Agreement
establishing the
EBRD to provide
financial support to
Central and
Eastern Europe.
EU accounting Conference: future of Harmonisation: giving a
evolutions harmonisation of new boost, alliance
accounting with the IASC.
standards (EU
Commission).
Romanian Accounting law 82/ Implementation OG 65/1994.
Accounting 1991. guidelines OMF
regulation 704/1993.
Romanian CECCAR (public
Accounting accountants)
and audit created by D 79/
profession 1991), after 30
years of previous
existence between
1921 and 1951.
Romanian Bucharest Stock
Financial exchange reopens
market after 50 years.
Early economic Government begins IMF agreement signed. First ‘cuponiada’: every Agreement with IMF Agreement with IMF IMF agreement: shock WB specifies conditions
reforms talks with IMF for a Privatisation: Law Romanian over 18 fails. fails. therapy for (creating an audit
loan. no.58/1991. years old received Use of MEBO Law no.55/1995, by economic reforms. institute, IAS
an ownership title privatisations. which the “Mass orientation).
allowing Privatisation
subscription of Program” was set
shares in in
companies owned motion (second
by the state. ‘cuponiada’).
(Continued)
153
154
Table 1. (Continued)
1998 1999 2000 2001 2002 2003 2004 2005 2006 2007
Significant The Europe An European Council is Visit of President Bush The EU and NATO sign Romania joins The accession of
events Agreements with held in Helsinki, in Romania; a security pact in NATO; The Romania and Bulgaria
Estonia, Latvia and Finland. It decides Invitation for Athens, Greece. Accession Treaty raises the number of
Lithuania enter into to open accession Romania to join enters into force Member States to 27 and
force. negotiations with NATO (Prague and the EU’s the population within the
Romania, Slovakia, summit). biggest Union to 492.8 million
Latvia, Lithuania, enlargement ever inhabitants.
Bulgaria and Malta becomes a reality
and to recognise with 10 new
Turkey as an countries - Cyprus,
applicant country. Czech Republic,
Estonia, Hungary,
Latvia, Lithuania,
Malta, Poland,
Slovak Republic,
and Slovenia -
together
representing more
than 100 million
citizens.
EU accounting Solution: new Block adoption of IAS/ Adoption of the revised Effective application of
evolutions harmonisation IFRS by the EU, IAS 32 and IAS 39. IAS/IFRS in the EU.
strategy, that is except for IAS 32
application of IAS/ and IAS 39.
IFRS.
Romanian OMFP 403/1999. OMFP 94/2001. OMFP 306/2002. OMF 22/2003. OMFP 1752/2005. OMFP 1121/2006.
accounting
regulation
Romanian ICAS, with funding from Law 133/2002 approves
accounting the UK the OUG 75/1999.
and audit Department for
profession International
Development, gives
support to create
the Chamber of
Financial Auditors
in Romania (based
on OUG 75/1999).
Romanian The Capital Market Law CNVM Regulation no. 1/2006
Financial no. 297/2004. on Issuers and
market Operations with
Securities; CNVM
Regulation no. 2/2006 on
Regulated Markets and
Alternative Trading
System.
Source: Official information from the institutional websites of the EU (www.europa.eu) and Romanian Government (www.gov.ro).
Accounting History 28(1)
Sandu et al. 155
Table 2. Interview description.
Code Role of the interviewee Scope
IC1 Broker engaged in the early activity of the Romanian financial Romanian context (financial
market market)
IC2 Head of Accounting and Reporting, Romanian listed company Romanian context (accounting
C1 and finance regulation)
IC3 Manager Corporate Development and Investor Relations, Romanian context (accounting
Romanian listed company C2 and finance regulation)
IC4 Manager Corporate Strategy and financial market, Romanian Romanian context (accounting
listed company C3 and finance regulation)
IC5 Investor Relationship Manager, Romanian listed company C4 Romanian context (accounting
and finance regulation)
IC6 Romanian academic in finance and restructuring, former Romanian context (early reforms)
member of the government during the early stage of the
reforms
IC7 Romanian financial analyst (working for international Romanian context (accounting
organisation) and finance regulation)
IC8 Manager within the CNVM (Romanian market authority) Romanian context (financial
market)
IA1 French member of IASB, participant in the first stage of the Accounting reform
accounting reform in Romania
IA2 Romanian academic in accounting, participant in accounting Accounting reform
reforms in Romania
IA3 Expert, academic, member ICAEW, participant to Know-how Accounting reform
missions in Poland
IA4 Expert, academic, member ICAEW, participant to Know-how Accounting reform
missions in Poland
IA5 French expert accountant, participant to the mission in Romania Accounting reform
Table 3. Relevant Romanian regulation related to the accounting reform (1989–2007).
Regulation Scope
Accounting law 82/1991 The keeping of accounts for all the natural and legal persons concerned
Law 79/1991 Ratification of the loan agreement with the IBRD
Implementation guidelines HG Guidelines for implementing the Accounting Law (82/1999)
704/1993
OG1 65/1994 Regulation of professional accounting practice and establishment of the
professional accountants’ association
OMFP2 403/1999 Implementation of accounting rules compliant with the 4th EU accounting
directive and the IFRS for a sample of large companies
OUG3 75/1999 Regulation of financial audit work and establishment of the professional
auditors’ association
OMFP 94/2001 Mandatory implementation of accounting rules compliant with the 4th EU
accounting directive and the IFRS by listed companies, large companies
and several State companies
OMFP 306/2002 Adoption of a set of simplified accounting rules compliant with the EU
accounting directives, to be implemented by small companies
Law 133/2002 Regulation of financial audit work and establishment of the professional
auditors’ association
(Continued)
Table 3. (Continued)
Regulation Scope
OMFP 1827/2003 Gradual implementation of accounting rules compliant with the 4th EU
accounting directive and the IFRS
OMFP 907/2005 Implementation of accounting rules compliant with the EU accounting
directives by all companies and implementation of IFRS by several types of
companies
OMFP 1752/2005 Adoption of the EU accounting directives in Romanian law
OMFP 1121/2006 Mandatory implementation of IFRS by listed companies and companies
preparing consolidated accounts
1
OG is the abbreviation in Romanian for Government ordinance.
2
OMFP is the abbreviation in Romanian for Order of the Ministry of Finance.
3
OUG is the abbreviation in Romanian for Government Emergency Ordinance.
Findings
The purpose of this section is to set out the findings of the study in terms of the accounting reforms
in Romania that includes the influence of the French and UK accounting professions and role of
academia.
The introduction of accounting principles in the Accounting Act of 1991 in Romania marked the
transition to accrual accounting, more adapted to the needs of the market economy. It is the period
of constructing financial accounting with a strong French influence, as presented by Richard (1995:
317), ‘The French influence in the new chart of accounts that the pro-French camp has managed to
have published may be described as overwhelming’.
There is a rather general consensus in the Romanian literature regarding the main stages of
accounting reforms, preceding EU accession (Ionaș cu, 2007; Calu et al., 2010). From 1991 to
1998 it is suggested that the regulation relative to the market economy (1993) was inspired by
the French model. Then from 1999 to 2005 it is suggested that the harmonisation regulations
(1999 and 2001) reflected the Romanian Ministry of Finance’s attempt to reconcile the
European Directives with the IAS/IFRS. Finally, after 2005, it is suggested that the compliance reg-
ulations (2005 and 2009) saw the adoption of the accounting Directives in view of Romania’s
accession to the EU on 1st January 2007.
We now look at these stages, to understand how the French influence was replaced by an IFRS
orientation, with help from the Know-how fund and UK accountants.
The French advisory role in the early stage of accounting reform

After the fall of the iron curtain, from the year 1990, the fight between capitalism and communism
was replaced by the confrontation between the various forms of capitalism, with the offensive of
stock exchange capitalism and of the related accounting system (Richard, 1999). At the inter-
national level, this means that the Anglo-Saxon accounting philosophy holds an ever-growing
importance, embodied by the IAS/IFRS, to the detriment of continental accounting.2 This phenom-
enon, which thus emerged more than 25 years ago, has become increasingly visible during the two
last decades, that is, since the 2000s.
For a long time, France has attempted to encourage the export of its accounting model (which is
continental), especially to the countries of southern Europe and to the former French colonies. In the
Sandu et al. 157
1990s this type of policy was implemented with the countries from Central and Eastern Europe
(CEE) and the communist countries in Asia (China, Vietnam), using models largely inspired by
the French accounting standards. Despite considerable efforts, results have been mixed, with
many failures and some successes, in particular in small countries such as Romania (Richard,
1999).
For the French profession, the need for accounting reforms in transition countries is clearly
regarded as an opportunity. Gilbert Gélard, who was technical and international director of the
Supreme Council of the Ordre des Experts Comptables (OEC), the French association of profes-
sional accountants (1987–1995), asserted that:
when building a market economy, the role assigned to accounting is different from the one that we know in
developed western countries: accounting has the single historical opportunity to be one of the driving forces
of development instead of accompanying it.3
Moreover, the objectives of the OEC in the CEE countries were clearly stated as being to
propose an accounting system inspired by the French system as a reference (this would in addition
facilitate the installation of French companies and accounting firms); to assist in setting up a training
program based on the French accounting philosophy; and to mobilise the French accounting pro-
fession towards new markets.
The Système Comptable d’Entreprise

In 1990, the French accounting profession and the Ministry of Economy and Finances decided to
take action in the field of international accounting cooperation, in order to preserve and defend the
continental system, threatened by the growing influence of the Anglo-Saxon practice. An account-
ing guide adapted to the countries moving towards a market economy was to be designed, building
on three references: the French Plan Comptable Général (PCG) (1982 issue), the European
accounting directives and the IASC standards. The purpose was to provide ‘an instrument for train-
ing, discussion, analysis and the definition of a new terminology based on a continental accounting
framework, in opposition to the Anglo-Saxon practice’.4
The outcome of the development process, decided and implemented by the Superior Council of
the OEC, was the enterprise accounting system (Système Comptable d’Entreprise – SCE), which
was the subject of a book published in 1991 (Delesalle et Gélard, 1991). It was intended to be
exported to countries in transition to a market economy, while adapting the proposed solutions
to the specificities of each country. According to its authors, it was not conceived as a model to
be replicated as such elsewhere, but rather as a technical document containing a set of rules,
mechanisms, and financial statement templates. The ambitions were rather high, as the purpose
of the new system was ‘to participate in the development and the evolution of accounting standard-
isation, as a theoretical and practical tool’.5
The SCE was conceived with a clearly visible (and stated) political purpose: to serve as an instru-
ment for promoting the French, and therefore continental accounting philosophy in the countries in
transition towards the market economy. Initiated by the OEC, with the assistance of the French
advisory body on accounting standardisation (Conseil National de la Comptabilité – CNC),
where all relevant stakeholders were represented, the project was carried out under the patronage
of the Ministry of Economy, Finances and Budget. The timing was perfect, as the first draft was
finalised in September 1990 and the final document (Delesalle et Gélard, 1991) was published in
January 1991, the year when the cooperation agreements with the CEE countries were signed.
As for the positioning of the SCE in relation to ‘competition’, Delesalle clearly stated that the
system was designed as ‘an instrument for the continental system, that is, an instrument against the
Anglo-Saxon domination in accounting’.6
Beyond the technical aspects that will not be developed here, the SCE has certain interesting
features regarding its design as well as its practical adaptation. It contains a glossary where the
most important concepts of an accounting system in a context of market economy are detailed,
with the goal of facilitating the appropriation of the model by the foreign partners. Certain sen-
sitive topics are discussed, and solutions are recommended, for example the connection between
accounting and taxation, the elements of manufacturing costs, and the calculation of the profit or
loss and so on. The suggested chart of accounts proposed is decimal and is clearly inspired by
the French PCG. The SCE also makes proposals concerning accounting reforms: it seems to
favour a partnership approach, focusing on the dialogue between the various stakeholders
during the development of a new accounting system, similar to the standardisation process
used in France.
Concretely, in 1991, the SCE was the basis for technical exchanges between the OEC and the
standard setters from certain CEE countries, as well as for exchanges at international level on
the choice of an accounting system (e.g. in French-speaking Africa). It was also used for the prac-
tical training provided by the OEC to more than four hundred Polish, Romanian, Czech and Slovak
accounting practitioners, in a program assisted by the French State (the SCE was translated into the
languages of the different countries).
The advisory mission to Romania

A cooperation program between the French accounting profession (supported by the State) and the
CEE countries was established in 1990. In this context, the OEC and the French association of pro-
fessional auditors (Compagnie Nationale des Commissaires aux Comptes – CNCC) carried out
technical assistance missions regarding accounting and professional training in Bulgaria,
Hungary, Poland, Czechoslovakia, Romania, Russia and Yugoslavia. In addition, in Poland,
Romania and Czechoslovakia, the cooperation agreements provided for the presentation and the
promotion of the SCE through training seminars. According to the members of the advisory mis-
sions, these were performed while respecting the following points: not to present models, show
availability and contribute to the development of an accounting framework compatible with
European practice and of an accounting profession.
The system appeared as a continental accounting model, which was confronted in the CEE coun-
tries with alternative offers, in particular of Anglo-Saxon inspiration, coming from various coun-
tries. This competition between the two accounting philosophies, as well as the increasing threat
of the Anglo-Saxon model, were clearly perceived by the French accounting professionals and
all their actions were aimed at defending their own interests.
In Romania, in 1990 and 1991, namely immediately after the fall of communism, authorities
started studying the EU accounting directives (it should be recalled that the initial purpose was
the integration into the EU) and discussing with experts from France, Germany and the UK
about accounting standardisation. Eventually a choice was made, and a cooperation agreement
signed on 24th July 1991 between the French and Romanian ministries in charge of the
economy, the OEC and the CNCC. The French project leader was Eric Delesalle, expert accountant,
who was also a professor and co-creator of the SCE with Gilbert Gélard. As was the case for all
CEE countries, this convention covered a number of points including assistance with the implemen-
tation of an accounting system adapted to market economy conditions; training of local accounting
practitioners in the fields of business economics, accounting and management; assistance with orga-
nising the accounting profession and the practice of accounting; bilateral annual meetings between
Sandu et al. 159
professional organisations; and organising visits in French accounting firms from foreign profes-
sionals, with internships in accounting expertise and legal audit.
In 1991, an accounting law was promulgated in Romania and it was detailed by governmental
ordinance in 1992. In 1992 also the authorities created a consultative body for accounting standard-
isation, whose attributions remained however rather limited, as the government retained the entire
power. The following year, in 1993, with the participation of the UE assistance programme for the
CEE countries (PHARE), the new accounting system was tested in 75 Romanian companies, with
the help of French and Belgian experts. After some adjustments, it became effective starting 1st
January 1994. The accounting profession was organised by governmental ordinance in 1994,
with the creation of an association and the definition of the missions.
The continental characteristics were very visible in the new accounting system (Delesalle,
1994). This included a coherent legal framework and precise terminology, separation between
a standardised financial accounting and a mandatory but freely organised management
accounting, the ‘imagine fidelǎ ’ objective (literally translated from the French ‘image fidèle’,
an equivalent of the true and fair view), clearly stated accounting principles (prudence,
consistency, going concern and so on), annual establishment of the financial statements
comprising a balance sheet, an income statement and the notes, and the existence of a chart of
accounts with the explanation of their operation. According to Delesalle (1994), some reminis-
cences of the centralised economy period subsisted, such as the prevailing role of the ministry
in charge of the economy in the standardisation process, the obligation to calculate a
precise profit or loss each month, particular approaches in cost calculation and analysis of
equity, and the particularly severe rules regarding the keeping and maintenance of accounting
records.
The next stage of the accounting reforms brings into the arena the technical assistance from UK
experts, through programmes financed by the Know-how Fund.
Twists and turns of the accounting reform: the role of the UK and Know-how Fund
The involvement of the UK in Romania, through the Know-how Fund, can be seen as a direct result of
UK transformational diplomacy in the aftermath of the cold war (Hamilton, 2013). This British funding
was decided in reaction to political developments in Poland in 1988, and it was further extended to other
post-communist countries, in order to help these countries to develop and enhance security, as part of the
post-cold war policies of Margaret Thatcher’s Conservative Government.
However, besides the political aspects of the help, it was mentioned at several moments in drafts,
white papers and internal documents of the Know-how Fund that helping these countries to recon-
struct would enable the UK to gain influence in this area (in direct competition with Germany and
France). In a second stage, when the European accession process was clear for most of these coun-
tries, it was also meant to help in creating future partnerships within the EU (Hamilton, 2013). This
was to ensure the UK was not outmanoeuvred: ‘…we may well be upstaged by the Germans’
(Ratford, quoted by Hamilton, 2013: 14).
However, it is important to note that the Know-how Fund was initially very reluctant to extend
help in Romania (as well as Bulgaria), because of the difficult political situation in the early years
of transition, and because of the instability of reforms. Despite early-developed missions in
Poland for instance (November 1989, focusing amongst other domains on the accountancy
sector, at both professional and technician levels), the Romanian revolution did not open
similar fields of intervention for the Know-how Fund, which was very cautious on entering
these new unstable territories.
Nevertheless, the Romanian officials openly expressed their need for funding from the UK, since
the early days of the transition. For example, Michael Atkinson, British Ambassador in Romania,
reported in January 1990 ‘an undercurrent of dissatisfaction filtering back from prominent members
of the NFS7 who feel that the UK is lagging behind some of our European partners, most notably
French and Germans, in responding bilaterally to Romania’s immediate practical needs’ (quoted by
Hamilton, 2013: 49).
As the much-awaited help was not yet agreed (despite existing small programmes, focusing
mainly on medical help), some of the Know-how officials began to echo the demands coming
from Romania: ‘Romanians wanted British help if only to ‘counterbalance the aggressive
French’, and even a small fund would ‘represent a disproportionate political benefit’ (Lewis,
January 1991, quoted by Hamilton, 2013: 122).
Starting in 1995, the Know-how Fund began to phase down and prepare an exit phase, also in
order to redirect British help towards countries in need from Africa and Asia. This was because the
political situation in Eastern Europe was no longer of immediate concern (a policy turning towards
poorer countries which was finally enacted by the New Labour government, after the 1997 elec-
tions). The fund decided to phase-down the help in other EU candidate countries (like Poland
and Hungary), that were well developed, and now had different needs. However, it is interesting
to note that this was precisely the moment when UK influence became of relevance in the account-
ing reform in Romania. This is because the Know-how Fund decided then that countries like
Romania and Bulgaria had finally taken a clear reforming path, aiming to EU accession (see the
major EU accession phases in Table 1).
Moreover, the new strategy of the fund was to focus on fewer but more important projects, with
the main concern identified in Romania, in addition to problems of poverty and corruption, being
the lack of proper frameworks in several areas, including finance. The need for transparency and
protecting the population from asset and income misuse and hijacking (Hamilton, 2013) was
clearly related to the accounting reform.
Therefore, the accounting reform in Romania moved in this precise period towards an
Anglo-Saxon model, with assistance from ICAS (Scotland) (One of the UK’s main accounting profes-
sional bodies) and funded by the Know-how Fund of the UK. In September 1996 the British
Government, under its Know-how Fund banner, provided assistance to the Romanian Ministry of
Finance, Accounting Legislation Department, to further develop the accounting system (King et al., 2001).
The orientation towards international accounting standards was therefore part of a broader movement
of development of transparency in relation to the financial market and the accounting regulations, under
the pressure of international bodies such as the World Bank and the International Monetary Fund (IMF)
for better governance. Moreover, this is part of the post-cold war transformational diplomacy consisting
in assistance through funding and know how to support emerging democracies.
Discussion
As a theoretical contribution we suggest that broader geopolitical processes, and postcolonial influ-
ence without an empire, were at play through the accounting reforms, facilitating transition from a
planned to market economy as Romania moved from communism to capitalism.
Indeed, we find that accounting reforms were not solely driven by technical arguments, or inter-
ests of the actors directly involved, but they are interconnected with, and reflect, a broader geopol-
itical setting. As a result, there is a role played by accounting academics due to the absence of an
organised profession and a periphery view of the geopolitics of accounting regulation.
Sandu et al. 161
The role of accounting academics: filling the gap in the absence of an organised
profession
The accounting reforms were not just the preserve of foreign accounting bodies. Moreover, as a
profession did not exist in the western sense, it was academics who were able to bridge the gap.
Indeed, our research further develops this argument on the basis of parallel interviews gathered
in Romania and France. For example, one of the interviewees (French expert accountant with
high responsibilities in the Ordre des Experts Comptables8 OEC), who was an actor in the initial
stage of the accounting reform in Romania, identified two main categories of participants to early pre-
sentations and meetings with foreign specialists in Romania, after the fall of communism: the Ministry
of Finance and the academics. Throughout the discussion, while trying to grasp the meaning of this
observation, we were able to confirm the finding that accounting practitioners were not actively involved
at the beginning of the accounting reforms, and neither was the accounting profession (which is under-
standable, as it was not organised in the form of an association until 1992).
At the end of 1991, training sessions took place in some of the most important Romanian
cities (Bucharest, Cluj, Timisoara and Iasi). As noted by a member of the French team: ‘at that
time everything was changing in Romania […] I was there exactly when there was a legislative
effervescence and every day something new appeared’ (IA5). The sessions were welcomed,
however the local participants had difficulties in understanding the operation of accounting in a free-
market context9. According to a French expert, there was also a conflict between the old and the
new generation:
I completely felt like a struggle for influence, a struggle for power, knowledge for power. […] We clearly
perceived this generational shift, this paradigm shift, and with it, we always say the same thing, the one who
holds the information holds the power (IA5).
The few practitioners that were present had difficulties in understanding the new accounting
system, as this meant understanding both the logic of the free market and accounting techniques.
An oral history anecdote expresses this great abyss from which the accountants were coming out:
after the explanation of the depreciation system, a very old accountant had exclaimed: ‘Yes, I
know what this is! I finally understand! I have seen this before the war10!’(IA1). Often very
old, these practitioners could not represent the link that would renew the connection with the free-
market practices and the suitable accounting techniques. This supports Bailey’s statement on neu-
tralisation of accounting during communism (Bailey, 1995), where accounting was used as an
instrument of control, being incorporated to the centralised planification system. Accountants
were little familiar to the accounting techniques and mechanisms of the market, while academics
could take more easily a leading role in the very early stage of accounting reform, based on their
knowledge capital.
The academic leadership in the early stage of reforms corroborates with the thesis of cultural
French affinities, and the access to a French type of accounting before the fall of communism.
As stated by one of the interviewees, visiting missions allowed to some academics in North
Africa enabled a direct contact and enhanced familiarity with the French accounting, which was
used in these post-colonial settings (IA2).
Therefore, accounting academics (coming mainly from public universities) ensured the con-
nection with the international experts of free market economies and also with the past; they
ensured the transmission of the new accounting logic, at least during the early years of reform.
This important role played by academics in the modelling and in the transmission of practices,
while the profession was not yet organised, has not been often mentioned in the ature, and
represents one of the contributions of this article. Of course, historical studies on the relation
between profession and education acknowledges the important role played by education and aca-
demics during the process of professionalisation. It has also analysed the mutual influences between
praxis and academia (Anisette and Kirkham, 2007; Njokua et al., 2010), but the connecting role
played by academics in the absence of a developed professional community has not yet been
studied in accounting research.
Geopolitics of accounting regulation: through the lenses of periphery

As we were able to see in the prior section, the accounting reforms in Romania follow surprising
turns between a French inspired model, international standards, and European regulations. There
are various ways to explain these twists and turns: cultural affinities, economic interests and the
drivers of the EU accession process.
After the fall of communism, a number of French experts were particularly active in the inter-
national support (Eric Delasalle, Gilbert Gélard and Louis Klee). They were important players of
the first accounting reform in Romania. Their assistance was accompanied by injection of public
funds, justified by the strategic interest of France to increase its influence in a traditionally franco-
phone and francophile country.
One explanation for the initial selection of French models of the accounting reform in Romania
is based on socio-cultural factors. A second explanation is based on the mutual interest of a
Romanian accounting elite with French education and affinities and of France as a strategic investor
in the region, to build a system and an accounting logic in their own image. A third more neutral
explanation is relative to the context of European integration and correlates the French-style reform
with the Fourth European Directive (King et al., 2001).
The last reason concerning European integration is highly sustained by our data. For instance,
the interview with the French expert points three main routes of reform (Conservative,
pro-Anglo-Saxon, and pro-French), based on collaborations established between Romanian profes-
sors and French experts, but also based on the orientation, which was clearer to the French experts
(and less to local ones), on a future possible integration of Romania in the EU, thus involving
already the need for accounting harmonisation with the European directives (IA1). This represents
a step further compared to the French system, a step that foreign experts were willing to take, but
which sometimes gave rise to protests from local teams: ‘But are the French doing this too? …No…
Well, then neither will we!’(IA1).
The expert further observes (quoting also Feleagǎ , a Romanian academic and influential
accounting professor) that it was more a power struggle between three parties -
Conservative, pro-Anglo-Saxon and pro-French - reflected terms of influence on the design
of the new accounting system. These different explanations appear also in the debate
between Feleagǎ , who favours the technical arguments11, and Richard (1995), who insists
on the political and cultural aspects. For Feleagǎ (1992), the features of the 1991 Romanian
accounting framework could be explained by the need to simultaneously obtain micro and
macroeconomic data for a wide range of users and to implement a system well adapted to the char-
acteristics of the local economy (predominance of small and medium sized companies, market and
State-based financing). Richard (1995) emphasises the conflict between the three parties already men-
tioned, stating that eventually the pro-French camp won this struggle for power. In addition, the pref-
erence for the French model could be explained by economic and cultural reasons. In the 1990s,
French investments were very important in Romania and, at least during that period, the French
culture appeared to be particularly influential. Later, Feleagǎ and Feleagǎ (2016) attempted to
Sandu et al. 163
synthesise all arguments through tradition, cultural relations, scientific and economic exchanges and
need to comply with the EU directives. However, this choice of the Romanian authorities, that is,
the implementation of an accounting framework largely inspired by the French, remains difficult to
fully understand (Roberts, 2001).
In one of the interviews, a member of the French mission in Romania clearly drew a parallel with
the case of the French former colonies: ‘I had already gone to Africa with a cooperation mission,
and I had implemented the OCAM plan12. The SCE was exactly the same thing as the OCAM plan,
as the French PCG’ (IA5). However, the approach was different:
In Africa it was easier, because we brought things along, we put them in place, we contributed to the evo-
lution, but we weren’t replacing a completely different system. We went in the right direction and we made
things change. It was more of pure cooperation, whereas in Romania, in Bucharest, you had to put a cross
on the past to build something else. There was this rupture that there hadn’t been in Africa (IA5).
The French episode is often discussed from a cultural point of view, as a smoother and more
easily accepted transition from an accounting adapted to central planning, to an accounting for
the free market (Feleagǎ , 1992; Richard, 1995; Feleagǎ and Feleagǎ , 2016). The replacement
with an IFRS oriented system is often understood, especially in the local literature, as a turn to a
more adapted system (technically designed for the market), in line with evolutions at the inter-
national level, having of course its costs (Ionaș cu et al., 2006, 2007). Moreover, some of the litera-
ture identifies a paradox in Romania, being more open to a prompt adoption of IFRS (including the
newest projects), than France for instance, which resisted explicitly and vigorously to their imple-
mentation (Albu et al., 2011; Ionaș cu, 2007).
However, the process and choices are similar with what happened in other ‘singular’ post-
colonial contexts, like Cambodia (Yapa et al., 2016), where the French influence was just a temporary
episode in the alignment with international standards, promoted by international professional bodies. By
comparing the two cases, we argue that this is linked to the need to bridge between planned economy
and market, based in our case on cultural affinities and familiarity of the French system for Romanian
academics involved in the early stage of reforms. However, the broader processes (transformation dip-
lomacy as instrument of globalisation, international accounting harmonisation in Europe and Romania’s
EU accession) drive the final direction of accounting reforms and set their pace.
Ionaș cu et al. (2006) consider that the regulations adopted in Romania in 1999 (Order No. 403/
1999) mark the reorientation of the Romanian accounting to international accounting standards, as
the IASB conceptual framework was integrated into the regulations. The conclusion of Ionaș cu et al.
(2006) is that the decision to harmonise the Romanian accounting with IAS / IFRS was not part of
the strategy for accession to the EU (nor was it opposed to it), but it rather represented an adaptation
to the accession strategy of a process of harmonisation started under the pressure of international
finance organisations, and under the counsel of the Know-how Fund. Therefore, a game of influence
and power took place locally, involving national experts from developed countries as global players.
The Know-how Fund was previously involved in the architecture of the accounting reform in
Poland, an experience that developed in connection with the evolution of financial markets.
Considering the role of academics in the accounting reform of transition countries, the experience of
other countries is also illustrative, in this case through the Know-how Fund in Poland: ‘In Poland there
have been various programmes sponsored by the British Know-How Fund and exchanges between
Polish academics and Western universities’ (Baruga and Bailey, quoted by King et al., 2001: 71).
The fact that the Know-how Fund waited longer before stepping in to support Romanian reforms
was mainly a question of funds available (IA4), and a balance between diplomatic ambitions and
public and parliamentary expectations (Hamilton, 2013). Also, other national and supra-national
organisations were entering specific areas of the reforms (like USAID for the democracy and free
market project), with higher funds, and a higher impact.
Standardisation is seen in the literature as a means of building global order. Djelic and
Sahlin-Andersson (2006) studied the shift in governance from a professional logic to a market
logic. Our story sustains the case of a different, more dramatic shift, from plan to market logic,
engaging actors from developed countries which are already involved in the transnational regula-
tion games. ‘Tensions between conflicting interests, perceptions and strategies were often dealt with
at a more subtle level and appeared as hidden sub-text of official rhetorics’ (Djelic and
Sahlin-Andersson, 2006: 287). In our case, official rhetoric included diplomacy and politics in
the context of EU accession/enlargement.
Moreover, the Romanian State was re-placed on the map (in the geopolitical sense) in the European
market context. Therefore, the accounting field provided the needed management, business and govern-
ance mechanisms adapted to the new market, and needed to operate the transition, in line with the EU
market logic, and adjusting the pace of change to European accounting reforms.
Expert advisors also pushed their own agenda, which was changing in the context of the conflicts
between transnational and national regulation. This episode shows how these struggles are evident
not only at the centre, but also reflected by the periphery, and can become a political resource for the
actors engaged.
In addition, the tools and technologies used in reforming are marked by the geopolitical lenses of
the developed countries. France and UK therefore promoted their national programmes, but they
were both part of a broader movement of globalisation (transnational regulations with IFRS).
The speed is different, and forces are sometimes converging, sometimes opposing. France
follows its own economic and political agenda: the models used are post-colonial, importing the
same system that they recommend in Africa for their former colonies (for reasons of simplicity
of application). UK follows the agenda of transformational diplomacy, following US. However,
the Victorian UK already included behaviour of what Gallagher and Robinson (1953) called ‘infor-
mal empire’ in former colonies. Therefore, the pattern is not new.
The output of the accounting reform was finally the adoption of the EU directives (as part of the
accession process). Also, a European movement towards IFRS (despite debates and resistance of
several national models), characterised the accounting regulation arena in the same period. This
episode of ‘confrontation’ in the field of accounting is therefore part of the Europeanisation, and
globalisation processes, accelerated after the fall of communism.
Conclusions
Providing a proper framework for business governance, by reforming regulation and management
practices (including accounting) has been a major challenge for transitional economies after the fall
of communism. The need to improve governance through the quality of financial reporting in these
countries and the orientation towards a new age of financial disclosure are mentioned in many
expert reports of foreign or international organisations (the World Bank, the European Bank of
Reconstruction and Development, the Organization for Economic Co-operation and
Development, USAID and the Know-how Fund). Accounting becomes in this context a factor of
stability, and a major stake for these young democracies in the geopolitical arena.
Our article provides a mapping of accounting reforms in a transition to market context. We give
therefore a detailed account of how competing experts from developed countries were stepping in
uncharted accounting territories, as part of a broader globalisation process. The replacement of an
accounting reform parented by French experts, with a new accounting reform under a clear
Anglo-Saxon influence shows that the choice of reforms in accounting is not determined solely
Sandu et al. 165
by the search for efficient technical solutions, but is most often driven by several types of actors and
struggles: local experts looking for legitimacy on the basis of cultural background and affinities;
experts and consultants from developed countries looking to expand their influence, and hence,
gaining an economic, cultural and social capital; and last but not least, direct influence from national
and international aid and reconstruction agencies, as part of a more complex game of geopolitics (in
this case, transformational diplomacy in a post-cold war context).
Therefore, this article brings a contribution to two inter-connected streams of research: (1) a geo-
political reading of the role of developed countries in transmitting and transforming accounting at
the periphery (Annisette, 1999; Mennicken, 2010); and (2) professional accounting literature, in a
transnational context (Annisette, 2000; Arnold, 2005; Bakre, 2005; Caramanis, 2002).
Yapa et al. (2016) found that accounting provides the needed structure and tools to support eco-
nomic development. In our case, focused on the context of transition to market economy in post-
communist European countries including the unique phenomenon of European integration, we
found that the various possible directions of development (international, European, local) and
the concomitant international processes (transformation diplomacy in western countries, account-
ing harmonisation in Europe, and so on) are shaping the local choices and pace of reforms.
Moreover, our article is answering to a call for more studies on accounting and territorialisation
(Mennicken and Miller, 2012), by directly addressing the impact of transformational diplomacy in
post-communist accounting reforms.
We find that the twists and turns of accounting reforms in Romania are echoing (with surprising
delays or accelerations) the broader processes in the international regulatory field. This finding is in
line with Djelic and Sahlin-Andersson (2006), who show that the dynamic development of the regu-
latory field implies that the form and content of financial reporting standards have gone through
numerous re-negotiations and revisions, in a still ongoing process. This process was studied at
the ‘centre’, however studying at the periphery (with transitional and emerging economies) can
shed more light on the global accounting regulatory process.
Also, we bring a contribution to the literature on professions, by revealing the role of academics
in the early stages of the reform, when there was no established accounting profession. This is in
line with Ashraf et al. (2020: 262), pointing out that in emerging economies ‘universities are per-
ceived as a cog in the machinery of economic development, to create a professional workforce for
businesses and government organisations’, where applied research is perceived as useful, providing
academics with ‘credibility to act as paid consultants and advisers, rather than conducting research.’
However, one main limitation of the article is the lack of detailed information on the ICAS mission,
as well as the fact that no interviews were taken with members of the UK team directly involved in the
Romanian accounting reform. Nevertheless, the authors have dealt with this limitation by relying on
literature and secondary data, mainly from reports of the Know-how fund that clearly reflected the pol-
itical aspects of funding reforms in the later stage of transition in Romania. Moreover, we have added
two interviews with members of UK advisory missions (ICAEW) in other Eastern European countries.
Further research should focus on different forms and paces of accounting reforms in other tran-
sitional economies, as well as on the struggles and strategies deployed by actors involved, to bring
more light on the role of diplomacy, national agencies and supranational organisations in construct-
ing, maintaining and transforming accounting regimes (Jones and Dugdale, 2001).
Acknowledgements
We would like to thank David Alexander for his insightful inputs to this research, to the participants to the 2016
workshop of the Historical Studies Research Group at Durham University for their suggestions in an early
stage of the paper, as well as to the participants to the Accounting History International Conference in
Verona 2017 for their useful comments.
Funding
The author(s) received no financial support for the research, authorship, and/or publication of this article.
Declaration of conflicting interests

The author(s) declared no potential conflicts of interest with respect to the research, authorship, and/or publi-
cation of this article.
ORCID iD
Raluca Sandu https://orcid.org/0000-0002-9279-3874
Notes
1. Previously, European attempts to obtain mutual recognition of the accounting standards with the US had
failed. The US had shown little interest, as the US GAAP were de facto already recognised in Europe, but
this was not the case in the USA for the European directives.
2. This notion, generally well accepted, is sometimes challenged (Walton, 1993), but the existence of a
common historical basis is obvious: the widespread dissemination of the Napoleonic commerce code
across continental Europe during the nineteenth century.
3. Revue Française de Comptabilite, no. 233, avril 1992, p. 52.
4. Le SCE, un an après, Revue Française de Comptabilité, no. 233, avril 1992, E. Delesalle, p. 24.
5. Exporter la comptabilité. Le système comptable d’entreprise, Revue Française de Comptabilité, no. 223,
mai 1991, E. Delesalle and G. Gélard, p. 75.
6. Revue Française de Comptabilite, no. 233, avril 1992, p. 61.
7. National Front of Salvation: main political party after the fall of communism, considered to have a strong
communist heritage.
8. The French expert comptable, as the Romanian expert contabil, do not have any equivalent in English.
Thus, following (Bocqueraz, 2001), it was translated here as expert accountant.
9. Revue Française de Comptabilite, no. 233, avril 1992.
10. In reference to WWII.
11. Revue Française de Comptabilite, no. 233, avril 1992.
12. The interviewee refers to the attempts to set up a unified French-inspired accounting system in several
African countries, first within the OCAM (Organisation Commune Africaine et Malgache), an organisa-
tion of French-speaking African countries, created in 1965 and dissolved in 1985.
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Struggles in The Accounting Arena: A Geopolitical Reading of Romanian Accounting Reforms

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Research Article

Romanian accounting reforms journals.sagepub.com/home/ach

General background: a historical overview of Romania, and the roots of

Figure 1. Signiﬁcant events between 1989–2007 (EU and NATO accession).

Colonies without empire: the geopolitics of globalisation

Accounting profession, gaps and continuity

1989 1990 1991 1992 1993 1994 1995 1996 1997

Table 2. Interview description.

Code Role of the interviewee Scope

Table 3. Relevant Romanian regulation related to the accounting reform (1989–2007).

The French advisory role in the early stage of accounting reform

The Système Comptable d’Entreprise

The advisory mission to Romania

Geopolitics of accounting regulation: through the lenses of periphery

Declaration of conﬂicting interests

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